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                                                           July 9, 2024

Jing-Bin Chiang
Chief Executive Officer
J-Star Holding Co., Ltd.
7/F-1, No. 633, Sec. 2, Taiwan Blvd.
Xitun District, Taichung City 407
Taiwan (R.O.C.)

       Re: J-Star Holding Co., Ltd.
           Amendment No. 19 to Registration Statement on Form F-1
           Filed June 13, 2024
           File No. 333-263755
Dear Jing-Bin Chiang:

     We have reviewed your amended registration statement and have the
following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Amendment No. 19 to Registration Statement on Form F-1 filed June 13, 2024
Conventions that Apply to this Prospectus, page 12

1.     Please update the "information and statistics" and industry data and
estimates throughout
       the amendment to account for any new or updated guidance, such as the
data in the Frost
       & Sullivan report you commissioned, or reconfirm and disclose that there
is no such new
       or updated guidance, and that the current disclosure is the most up to
date. For example,
       we note the disclosure on page 78 of the amended registration statement
filed on June 13,
       2024 that "Looking forward, as the pandemic is gradually controlled, the
carbon fiber
       racket parts industry is expected to recover from 2021" appears to have
not been updated.
       As another example, we note the disclosure on page 79 of the amended
registration
       statement about the "2021 Physical Activity Council's Overview Report on
U.S.
       Participation" released by the Physical Activity Council.
 July 9, 2024
Page 2

Use of Proceeds, page 50

2.     Please update the disclosure about how you intend to use the net
proceeds of this offering
       and whether the amounts allocated to each purpose will be sufficient to
accomplish the
       intended use or whether you will require additional funds. In this
regard, we note that the
       uses and percentages disclosed here remain substantially similar to
prior amendments but
       the total aggregate expected proceeds has declined substantially. If you
will require
       additional funds, disclose the expected source, amount and nature of the
funding.


       Please contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at
202-551-3723 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Thomas Jones at 202-551-3602 or Geoffrey Kruczek at 202-551-3641 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing
cc:   Lawrence S. Venick, Esq.
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